RMD non owner 72 in 2022 - retired in 2023

I'm trying to confirm if the new new law changes the RBD for a non owner participant in a qualified plan that turned 72 in 2022, and retired in 2023.

Is his RBD 4/1/2024 for a 2023 RMD under the old rules?

Or since he retired in 2023 his RBD 4/1/2025 for for a 2024 RMD?

Thanks

Did the new rules change the RDB? I thought it just raised the age from 72 to 73. So if he is 73 in 2023 and separates service in 2023 wouldn't he need a 2023 RMD with an RBD of 4/1/2024? Am I missing something?

Agree with Lou S. here... new rules did not change RBD... which would be 4/1/24 for the situation outlined in OP.

If the plan’s governing documents do not specify 72 or 70½ for the applicable age, or the plan’s administrator presumes the plan’s sponsor will amend the plan and the amendment will have retroactive effect.

6 minutes ago, Peter Gulia said:

If the plan’s governing documents do not specify 72 or 70½ for the applicable age, or the plan’s administrator presumes the plan’s sponsor will amend the plan and the amendment will have retroactive effect.

In this case it's all the same as the participant is 73 in 2023, is a non 5% owner, and has separated service in 2023. Under original age 70 1/2 rule, Secure 1.0 - 72 rule or Secure 2.0 - 73 rule, I believe you would get the same result in this particular fact pattern.

That’s right for those particular facts, and thank you for correcting me.

My observation is that too many people imagine 73 is a particular plan’s applicable age without reading the plan’s governing documents and (if those documents state something else) without asking (even internally within an employer that serves as the plan’s sponsor and administrator) whether the plan’s sponsor intends to amend the plan.

Yes it's possible that the plan could require 70 1/2, 72, or 73 depending on operation and conforming amendments. But my understanding is that if the plan document follows an older rule for RMD because of the document they can continue to make the payments but they are eligible for rollover and subject to the 20% mandatory withholding. Maybe I'm wrong in that understanding.

2 hours ago, Lou S. said:

In this case it's all the same as the participant is 73 in 2023, is a non 5% owner, and has separated service in 2023. Under original age 70 1/2 rule, Secure 1.0 - 72 rule or Secure 2.0 - 73 rule, I believe you would get the same result in this particular fact pattern.

I knew something was off in my thinking.  This is the light bulb moment for me.

Thanks everyone.